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Viera v. City of New York

United States District Court, S.D. New York

January 14, 2020

CHRISTOPHER VIERA, GENADIY MINTS, DEVIN SPARKS, MOZADICK ALI, ANGELO DACHILLE, SHARRON DELILLY, CARL GRAHAM, JOSEPH GRANT, THOMAS HARTE, PATRICIA HINDS, HARRISON JOHNSON, CASSANDRA MURRAY, DARRELL NELSON, LESLIE PARRIS, NIGEL WILLIAMSON, and all others similarly situated, Plaintiffs,
v.
THE CITY OF NEW YORK, Defendant.

          Gregory K. McGillivary Sara L. Faulman Hillary Lebeau McGillivary Steele Elkin LLP Hope Pordy Elizabeth Sprotzer SPIVAK LIPTON LLP Gregory K. McGillivary McGillivary Steele Elkin LLP Hope Pordy Spivak Lipton LLP

          JAMES E. JOHNSON Corporation Counsel of the City of New York Attorney for Defendant

          Laura C. Williams Assistant Corporation Counsel

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         WHEREAS, all the parties to this action (collectively the “Parties” and individually a “Party”) request that the Court issue a protective order pursuant to Federal Rule of Civil Procedure 26(c) to protect the confidentiality of nonpublic and competitively sensitive information that they may need to disclose in connection with discovery in this action;

         WHEREAS, the Parties, through counsel, agree to the following terms; and

         WHEREAS, the Court finds good cause exists for issuance of an appropriately tailored confidentiality order governing the pretrial phase of this action, IT IS HEREBY ORDERED that any person subject to this Order - including without limitation the Parties to this action (including their respective corporate parents, successors, and assigns), their representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order - will adhere to the following terms:

         1. With respect to “Discovery Material” (i.e., information of any kind produced or disclosed in the course of discovery in this action) that a person has designated as “Confidential” pursuant to this Order, no person subject to this Order may disclose such Confidential Discovery Material to anyone else except as this Order expressly permits:

         2. The Party or person producing or disclosing Discovery Material (“Producing Party”) may designate as Confidential only the portion of such material that it reasonably and in good faith believes consists of:

a) any information concerning any third-party in the care, custody, and control of the Fire Department of the City of New York (“FDNY”);
b) any information of a personal or intimate nature regarding any individual who is not a plaintiff in this action;
c) previously non-disclosed business plans, product-development information, or marketing plans; or
d) any other category of information the Court subsequently affords confidential status.

         3. With respect to the Confidential portion of any Discovery Material other than deposition transcripts and exhibits, the Producing Party or its counsel may designate such portion as “Confidential” by: (a) marking “Confidential” on each page of the document or otherwise marking the Confidential portion “Confidential” in a fairly conspicuous fashion; or (b) by designating in writing the Bates-stamp numbered pages to be designated as “Confidential.”

         4. A Producing Party or its counsel may designate deposition exhibits or portions of deposition transcripts as Confidential Discovery Material either by: (a) indicating on the record during the deposition that a question calls for Confidential information, in which case the reporter will mark the designated testimony it as “Confidential Information Governed by Protective Order;” or (b) notifying the reporter and all counsel of record, in writing, within 30 days after receipt of the final transcript, of the specific pages and lines of the transcript that are to be designated “Confidential, ” in which case all counsel receiving the transcript will be responsible for marking the copies of the designated transcript in their possession or under their control as directed by the Producing Party or that person's counsel. During the 30-day period following a deposition, all Parties will treat the entire deposition transcript as if it had been designated Confidential. Any depositions taken in this action (where either the Confidential Discovery Material or the documents containing the Confidential Discovery Material may be disclosed or used) shall be attended only by the deponent, the deponent's attorney, the parties, the ...


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